CONFLICTS OF INTEREST POLICY

MF Financial is committed to acting honestly, fairly, and professionally in the best interests of our clients at all times. Given the nature of our work — advising high-net-worth individuals, founders, senior executives, international buyers, and portfolio landlords on complex and high-value mortgage arrangements — it is essential that we identify and manage any potential conflicts of interest with the highest level of transparency and integrity.

This policy explains how MF Financial identifies, manages, and mitigates potential conflicts of interest in line with FCA requirements.



Purpose of This Policy


The aim of this policy is to:

  1. Protect clients from unfair outcomes

  2. Ensure independent, unbiased mortgage advice

  3. Provide transparency around circumstances where conflicts may arise

  4. Comply with FCA regulation and maintain professional standards



Understanding Conflicts of Interest


A conflict of interest may occur when MF Financial’s duties to a client could be influenced by our own interests, relationships, or external factors.

Conflicts may be:

  1. Actual — a real and present conflict

  2. Potential — a situation that could lead to conflict

  3. Perceived — something that may appear to be a conflict to a client

Even if no improper action occurs, perceived conflicts must still be managed carefully.



Situations Where Conflicts May Arise


While MF Financial acts independently and does not operate a tied panel, conflicts may arise under certain circumstances, including:

a) Relationships with Lenders

  1. Personal or professional connections with lender staff

  2. Enhanced service arrangements offered by certain lenders

  3. Situations where a lender provides faster turnaround for specific intermediaries

We always recommend the most suitable lender for the client — not the one offering commercial preference.

b) Remuneration

  1. Commission or procuration fees received for mortgage placement

  2. Variations in fees between lenders that could influence adviser choice

  3. Internal incentives (MF Financial does not operate sales-based incentives)

All remuneration structures are disclosed openly to the client.

c) Multiple Clients with Overlapping Interests

  1. Two clients bidding on the same property

  2. Clients connected through business interests

  3. Shared exposure to the same lending institution or structure

Confidentiality is maintained at all times, and no information is shared between clients.

d) External Professional Relationships

MF Financial collaborates discreetly with:

  1. Private banks

  2. Specialist lenders

  3. Lawyers, tax advisers, and wealth managers

Where an external partner may benefit from a referral, we disclose any commercial arrangement.



How We Manage and Mitigate Conflicts


MF Financial has established procedures to ensure fair treatment and objective advice:

a) Disclosure

Where a conflict cannot be fully avoided, we clearly disclose it to the client before proceeding.

b) Adviser Objectivity

Advisers must always:

  1. Base recommendations solely on suitability for the client

  2. Avoid undue influence from relationships or remuneration

  3. Document reasoning behind each recommendation

c) No Sales Targets or Volume Incentives

We do not operate:

  1. Sales quotas

  2. Lender-volume targets

  3. Performance-based commission structures for advisers

This removes commercial bias from the advice process.

d) Confidentiality Controls

  1. Client files are securely stored

  2. Information is shared solely on a need-to-know basis

  3. No cross-client disclosure under any circumstances

e) Independent Compliance Oversight

An independent compliance function reviews:

  1. Advice files

  2. Remuneration practices

  3. Lender relationships

  4. Any identified conflicts



Declining or Withdrawing from a Case


If a conflict of interest cannot be appropriately managed, MF Financial may:

  1. Decline the engagement

  2. Withdraw from acting

  3. Recommend an alternative adviser

Client protection is always prioritised over commercial interest.



Staff Responsibilities


All staff and appointed representatives must:

  1. Recognise situations where conflicts may occur

  2. Escalate concerns immediately

  3. Maintain professional independence

  4. Act transparently and in the client’s best interests

Training on this policy is conducted regularly.



Ongoing Monitoring


MF Financial reviews this policy periodically to ensure alignment with:

  1. FCA regulations

  2. Industry best practices

  3. The evolving nature of client circumstances and lending markets

Updates are implemented promptly where needed.



Contact Us


If you require additional support or wish to discuss any circumstances that may affect your ability to engage with the mortgage process, please contact:

MF Financial Ltd

Email: es.salh@mortgagefnd.co.uk

Phone: 020 3151 0813

We are here to help, discreetly and without judgement.